Epstein Secrets

pstein) 2 "Decisions by the former Fifth Circuit issued before October 1, 1981, are binding as precedent in the Eleventh Circuit." United States v. Brown, 342 F.3d 1245, 1246 n.1 (11th Cir. 2003). 12 EFTA00304753 Case 9:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/2011 Page 13 of 25

sing with those that it does not. 9 Epstein, however, has sent in his surrogates to litigate in this case, including his criminal defense attorneys Roy Black et al. and an attorney who has represented persons close to him, Bruce Reinhart. 20 EFTA00304761 Case 9:08-cv-80736-KAM Document 127 Entered on FLSD D

recedent in the Eleventh Circuit." United States' Brown, 342 F.3d 1245, 1246 n.1 (11th Cir. 2003). 12

sing with those that it does not. 9 Epstein, however, has sent in his surrogates to litigate in this case, including his criminal defense attorneys Roy Black et al. and an attorney who has represented persons close to him, qtr 20 EFTA00204911 Case 9:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/

by any materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle. McClure, 332 F.3d 347, 1358 (11th Cir. 2003); Brown' City of Margate, 842 F.Supp. 515, 520 Should the Court allow the Government to assert privilege with regard to any of the materials, the victims w

Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 JIBlackaroyblack.com Attorneys for Proposed Intervenors Roy Black et al. Respectfully Submitted, S/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. EFTA00179736 Case